Food labelling in New Zealand
Understanding what ingredient lists and allergen warnings actually mean — especially "May contain" statements.
Two types of allergen information on NZ labels
New Zealand food labels can carry two very different types of allergen information. They look similar but mean quite different things.
Declared ingredient
The allergen is an intentional ingredient in the recipe. The manufacturer deliberately adds it. This is a mandatory declaration under FSANZ Standard 1.2.3.
Precautionary allergen label (PAL)
The allergen is not an ingredient, but it might end up in the product due to shared manufacturing equipment or ingredient sourcing. This is a voluntary cross-contamination warning.
What "May contain" actually means
A "May contain" or "May be present" statement means the manufacturer cannot guarantee the product is free of that allergen. This happens when:
- Shared equipment — the same production line or machinery is used to make products that contain the allergen. Even with cleaning, trace amounts may transfer.
- Shared facility — allergen-containing products are made in the same factory, and airborne particles or cleaning cross-contamination is possible.
- Ingredient sourcing — an ingredient supplier uses shared equipment, introducing risk before the product even reaches the manufacturer.
The statement is voluntary — the Food Standards Code does not require it. Some manufacturers add it proactively as a precaution; others in identical production environments may not. The absence of a "May contain" statement does not guarantee a product is allergen-free.
How DietTribe handles PAL statements
DietTribe distinguishes between confirmed ingredients and PAL statements when analysing products:
- Allergens listed as ingredients are shown under Unsafe ingredients — the product definitively contains that substance.
- Allergens appearing only in a "May contain" section are shown under May be present — marked separately in blue to make the distinction clear.
For people with coeliac disease, even trace amounts of gluten can cause intestinal damage. The Allergy New Zealand guidance is that individuals with severe food allergies or coeliac disease should treat "May contain" statements seriously and make their own judgement based on their sensitivity level.
Ingredients with an unclear source
Some ingredients are listed by name on the label without any indication of where they came from. The same ingredient name can refer to a product derived from completely different sources — one safe for a particular diet, one not.
Unclear gluten source
Certain ingredients can be derived from wheat (which contains gluten) or from gluten-free sources such as corn, potato, or tapioca. The label may not specify which.
Unclear animal source
A number of common additives can be produced from either plant or animal material. Without further information, vegetarians and vegans cannot determine suitability from the label alone.
These are not allergen labelling failures — manufacturers are not required to declare the source of these ingredients under current NZ food standards. However, the ambiguity is real and can matter for people with coeliac disease, gluten intolerance, or plant-based diets.
The Unclear gluten source and Unclear animal source filters on the product search page surface products that contain one or more of these ingredients, making it easier to identify which manufacturers to contact. Where a brand's contact details are available, they appear directly on the product page.
The law in New Zealand
Food allergen labelling in New Zealand is governed by the Australia New Zealand Food Standards Code, specifically Standard 1.2.3 — Mandatory Warning and Advisory Statements and Declarations.
The mandatory allergens that must be declared when present as ingredients include: peanuts, tree nuts, milk, eggs, sesame seeds, fish, shellfish, soy, wheat, and lupin. Gluten from wheat, rye, barley, and oats must also be declared.
PAL statements are not regulated — they are written by manufacturers at their own discretion. Work is ongoing internationally (including through FSANZ) to standardise PAL wording to make it less confusing for consumers.